Billions of Dollars in Funding: New Notices of Funding Opportunity Released by NTIA

2022-05-16T19:06:41-04:00May 16, 2022|e-Lerts|

On May 13, 2022, the US Department of Commerce’s National Telecommunications and Information Administration (NTIA) released three separate funding announcements — or “Notices of Funding Opportunity” (NOFOs) — detailing the eligibility requirements, deadlines, and rules for the $45 billion in broadband funding:

  1. Enabling Middle Mile Broadband Infrastructure Program – $1 billion:
    • The program will award $5-$100 million in grant funding to selected applicants to build middle mile facilities with interconnection points located within 1,000 feet of a Community Anchor Institution (e.g., school, library, or hospital).
    • Eligible entities include telecommunications companies, telecommunications cooperatives, technology companies, electric utilities, utility cooperatives, public utility districts, nonprofits (e.g., foundations, corporations, institutions, or associations), regional planning councils, native entities, economic development authorities, states, political subdivision of states, and tribal governments. Additionally, to a partnership of two (2) or more of the aforementioned entities.
    • JSI can help clients submit a Middle Mile Grant application directly to NTIA by the September 30, 2022, deadline.
  2. Broadband Equity, Access, and Deployment (BEAD) Program – $42.5 billion:
    • Program funding disbursed through the states can be used for projects to connect the unserved (lacking 25 Mbps / 3 Mbps) and underserved (lacking 100 Mbps / 20 Mbps) as well as to connect community anchor institutions.
    • Eligible entities include all 50 states and US territories. They must submit a Letter of Intent to NTIA by July 18, 2022, additional application materials by August 15, 2022, and up to 270 days to submit a five-year action plan to receive funding.
    • States are eligible for a minimum of $100 million each.
    • US Territories are eligible for a minimum of $25 million each.
  3. State Digital Equity Act Program – $1.5 billion:
    • In accordance with their respective Digital Equity Plans, states and territories will disburse grant funding to promote the achievement of digital equity, support digital inclusion activities, and build capacity for efforts by states related to broadband adoption.
    • Eligible applicants include all fifty states and US territories.
    • Completed applications are due July 12, 2022, for the fifty states, the District of Columbia, and Puerto Rico.
    • Letters of Intent from the US territories that wish to participate are also due July 12, 2022.

The Infrastructure Investment and Jobs Act allocated $45 billion to these three programs to deliver affordable high-speed broadband to Americans.

JSI will be providing more detail on each of these programs and how entities can take advantage of these opportunities. Should you have any questions, please contact Amanda Molina or Douglas Meredith for assistance by clicking the button below.

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Action Required by May 1: Affordable Connectivity Program – New Consumer Fee Field

2022-04-28T15:16:21-04:00April 27, 2022|e-Lerts|

As of March 31, 2022, Affordable Connectivity Program (ACP) providers must complete a new “Consumer Fee” field in the National Lifeline Accountability Database (NLAD).

This new Consumer Fee field indicates whether a consumer is charged a monthly fee for broadband service after the application of the ACP benefit, and it is required for all verification, enrollment, transfer, and update transactions in NLAD. In addition, by May 1, 2022, providers must update the Consumer Fee field for all subscribers enrolled in ACP prior to March 31, 2022.

Providers must perform an “update” transaction in NLAD to backfill the Consumer Fee field by entering a “1” to indicate that a fee will be assessed, or a “0” to indicate that no fee will be assessed.

If you have any questions concerning this new Consumer Fee field or any other ACP-related matter — including JSI’s new comprehensive “ACP Compliance Package,” which has been designed to help companies navigate the FCC’s complex ACP rules — please contact Lans Chase or Dounia Chikhoune for assistance by clicking the button below.

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Reminder: 988 Required Milestone Reporting to NANPA

2022-04-18T20:30:27-04:00April 15, 2022|e-Lerts|

The three-digit 988 dialing code, which provides direct access to the National Suicide Prevention and Mental Health Crisis hotline, will be effective on July 16, 2022. All telecommunications carriers must route 988 calls to the existing National Suicide Prevention Lifeline: 1-800-273-8255 (1-800-273-TALK). To accommodate 988 within all networks, carriers must implement mandatory 10-digit dialing in the number plan areas (NPAs) that use seven-digit dialing and 988 as an NXX.

The NPAs required to transition to 10-digit dialing are as follows:

State Affected NPAs
Alaska 907
Alabama 251
Arkansas 501
Arizona 480, 520, 928
California 209, 530, 562, 626, 650, 707, 925, 949, 951
Colorado 719, 970
Delaware 302
Florida 321 (Brevard County only), 352, 561, 941
Georgia 478, 912
Guam 671
Hawaii 808
Illinois 309, 618, 708
Indiana 219, 574
Iowa 319, 515
Kansas 620, 785
Kentucky 859
Louisiana 337, 504
Michigan 616, 810, 906, 989
Minnesota 218, 952
Mississippi 662
Missouri 314, 417, 660, 816
Montana 406
Nevada 775
New Hampshire 603
New Jersey 856, 908
New Mexico 505, 575
New York 516, 607, 716, 845, 914
North Carolina 910
Ohio 440, 513
South Dakota 605
Tennessee 731, 865
Texas 254, 361, 409, 806, 830, 915, 940
Vermont 802
Virginia 275, 804
Washington 509
Wisconsin 262, 414, 608, 920

All impacted service providers are required to provide a milestone completion status to the North American Numbering Plan (NANPA). Carriers must notify NANPA by email at 988@nanpa.com and include the relevant provider name, OCN(s), state(s), and NPA(s) in the email. In addition, carriers must provide carrier contact information to NANPA for troubleshooting of any permissive 10-digit dialing issues.

988/10DD Milestones to Report to NANPA:

Milestone Service Provider Required Action Due Date
8 Issue first customer notification. Carriers using bill messages may want to have these run multiple months rather than just one month to help ensure customers are aware of the upcoming dialing changes. 3/25/2021
11 Provide carrier contact information to NANPA for troubleshooting of any permissive 10-digit dialing issues. Include in the email: state(s), provider name, primary contact, telephone number(s), hours of operation, backup contact/escalations, email address, and telephone number(s). 4/10/2021
15 Carrier deadline to have permissive 10-digit dialing opened in their networks (carriers can implement this any time up to this deadline, no need to wait until the night before to implement). 4/24/2021
23 Issue second customer notification. Carriers using bill messages may want to have these run multiple months rather than just one month to help ensure customers are aware of the upcoming dialing changes. 9/24/2021
24 Carriers should be signaling/sending 10 digits of the called to party for all calls terminating in all end offices and access tandems in the area code. 9/24/2021
33 Carrier deadline to enforce mandatory 10-digit dialing (carriers have the interval between the mandatory 10DD effective date above and this deadline to remove 7DD and enforce 10DD on the schedule that works best for them). 7/15/2022

 

For help with your 988/10-digit dialing assistance reporting to NANPA, please contact Lisa Cover via email at lcover@jsitel.com or by simply clicking the “Contact Us” button below.

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Reminder: Annual Review of NENA ID Information

2022-04-16T13:26:56-04:00April 6, 2022|e-Lerts|

JSI Recommends That Its Clients Annually Review Their NENA ID Information

Have you checked your NENA ID profile lately? Is your ID still active? Are you wondering, “What is a NENA ID?”

What Is a NENA ID?

The National Emergency Number Association Identifier, commonly referred to as the NENA ID, is a unique three- to five-character code that helps 911 centers identify the service provider responsible for telephone numbers.

Why Is It Important?

The NENA ID is applied to telephone number records in the 911 database to help ensure that accurate caller location information can be provided to 911 centers and first responders when 911 is called. The ID also identifies the company responsible for the telephone number record in the 911 database.

What Is My Company’s Responsibility?

All service providers assigned a NENA ID are required to ensure the company’s contact information is current and accurate in the NENA database. In addition, the annual NENA ID invoices must be paid or the ID may be placed into inactive or canceled status.

What Happens If the NENA ID Is Flagged as Cancelled or Inactive?

The NENA Company ID status will be updated in the database indicating that the information has not been verified and is not confirmed to be accurate for 911 location identification services. A record remains in the database so that the ID is not reassigned, but eventually the associated information is subject to removal.

What Should I Do?

It is recommended that your company annually review and verify that the ID is still active and that all NENA ID data on file is accurate.

Let JSI Help.

JSI can provide you with your company’s current NENA ID data for your review, submit the necessary updates to the NENA ID administrator, notify your company once the updates are complete, keep records of the ID and any updates, as well as help you to bring canceled or inactive codes back to active status.

If you have any questions about this matter or need assistance with the annual NENA ID review, please contact Lisa Cover by clicking the button below or by calling 301-459-7590.

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FCC Requires Broadband Providers to Submit Supply Chain Reports by May 5 (Updated)

2022-04-14T14:30:46-04:00April 1, 2022|e-Lerts|

JSI Urges Its Clients to File Well in Advance of the Deadline to Allow Time to Address Potential Technical Glitches

In a recently released Public Notice, the FCC established a new reporting requirement as part of its obligations under the Secure and Trusted Communications Networks Act of 2019.

All broadband providers must now file what is known as the “Supply Chain Annual Report” no later than May 5, 2022. Notably, as part of this new reporting requirement, providers must certify whether their networks contain or use specific equipment or services obtained from five Chinese companies.

All JSI clients that provide broadband services must submit this report through the FCC’s newly created online reporting portal.

This new reporting requirement specifically applies to all providers of “high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality voice, data, graphics, and video telecommunications of at least 200 kbps in either direction.” Additionally, this requirement applies regardless of whether a covered broadband provider participated in the Secure and Trusted Communications Networks Reimbursement Program or filed the April 2020 report required of all eligible telecommunications carriers (ETCs).

In the Supply Chain Annual Report, broadband providers must confirm whether their networks contain or use specific equipment or services obtained from the relevant Chinese companies identified on the FCC’s Covered List, meaning that the equipment or services are considered to pose a threat to US national security interests.

Providers must answer “yes” if they have purchased, rented, leased, or otherwise obtained equipment or services on or after August 14, 2018, from one of the following companies, their subsidiaries, or affiliates:

  1. Huawei Technologies Company
  2. ZTE Corporation
  3. Hytera Communications Corporation
  4. Hangzhou Hikvision Digital Technology Company
  5. Dahua Technology Company

It should be noted that the last three companies manufacture video surveillance and telecommunications equipment that was not required to be included in April 2020 when the FCC required ETCs to file similar reports.

If your company uses any equipment or services meeting the requirements outlined above, it must provide a significant amount of detailed information to the FCC annually, including the locations, types, suppliers, historic and replacement cost, functionality, replacement plans, and a detailed explanation for your company’s decision to obtain that equipment. This year, the report will be due on May 5, 2022, and the deadline next year will be March 31, 2023.

On the other hand, if your company does not use any equipment or services identified on the Covered List, the filing is relatively streamlined and is only required once. Your company may need to make future filings if it starts using such equipment, or if the FCC adds your equipment to the Covered List.

With the FCC implementing this filing requirement for the first time, we urge clients to prepare and submit their filings as soon as possible and no later than mid-April. It has been our experience that new portal filing systems can be cumbersome and that filings can take longer than expected. Beginning the process now will help ensure that your company is not at risk of missing this filing deadline — one that pertains to critical national security concerns — and inviting an FCC enforcement inquiry. The reporting portal, instructions, and other information about the annual reporting requirement are now available at www.fcc.gov/supplychain.

If you have any questions about this new filing requirement or would like JSI’s assistance with this filing, please contact our subject-matter experts by clicking the button below.

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Upcoming Filing Deadline Reminders: Service Accessibility Compliance Certification and FCC Section 254(g) Certification

2022-03-30T09:25:12-04:00March 30, 2022|e-Lerts|

JSI reminds clients of two upcoming deadlines: (1) service accessibility compliance certifications (April 1, 2022) and (2) FCC Section 254(g) interexchange rate integration and rate averaging certification (May 1, 2022). Details are provided below.

Service Accessibility Compliance Certification

Telecommunications service providers have until April 1, 2022, to submit their certifications for the calendar year 2021 to the FCC regarding the accessibility of services for people with disabilities. The filing must be completed using the FCC’s Recordkeeping and Compliance Certification and Contact Information Registry at https://apps.fcc.gov/rccci-registry/. Specifically, providers must certify that they have established operating procedures to:

  • Document efforts to consult with individuals with disabilities;
  • Document the accessibility features of products and services; and
  • Record information about the compatibility of such products and services with peripheral devices or specialized customer premise equipment commonly used by individuals with disabilities to achieve access.

The FCC requires each company, and their affiliates that provide telecom services, to file the certifications. If previously submitted contact information remains current, the 2022 submission need only include the new compliance certification. Any updates to contact information must be made using the online registry within 30 days of the change.

FCC Section 254(g) Interexchange Rate Integration and Rate Averaging Certification

Each non-dominant provider of detariffed interstate interexchange service must certify by May 1, 2022, that it provides service in compliance with the geographic rate average and rate integration obligations pursuant to section 254(g) of the Communications Act. Geographic rate averaging prohibits a company from charging different rates for calls of similar geographic scope. Providers must certify annually that pricing policies are not discriminatory among rural and high-cost areas and that rates charged in each state are no higher than rates charged to any other state.

Clients who need assistance with either of these filings should contact Kim Waldvogel in our Maryland office at 301-459-7590 or via email by using the button below.

Wisconsin Broadband Expansion Grant Program: Objection Period Now Open

2022-03-28T17:58:58-04:00March 28, 2022|e-Lerts|

JSI Encourages Wisconsin Clients to Check Proposed Project Areas in Recently Filed Applications and Confirm Whether There Is Any Overlap

The Public Service Commission of Wisconsin (PSC) opened the window to object to grant applications filed under the Broadband Expansion Grant Program. Interested parties must file their comments opposing an application on or before April 14, 2022, at 4:00 pm (CT) using the PSC’s electronic filing system under Docket 5-BF-2022. Providers should address such objections to the Secretary to the Commission, Public Service Commission of Wisconsin.

Objectors should be prepared to demonstrate why the PSC should reject the application. Commenters should focus on deficiencies in the application, such as factual inaccuracies, ineligibility, or why the grant funds would be better spent elsewhere.

Grant applicants facing an objection have until April 21, 2022, at 4:00 pm (CT) to submit a response.

If you would like assistance submitting an objection, responding to an objection filed against your grant application, or have a question about this process, please click the button below to connect with one of our experts.

Cybersecurity Warning

2022-03-23T17:56:34-04:00March 22, 2022|e-Lerts|

Critical Infrastructure Organizations Should Bolster Their Cyber Defenses

On March 21, President Biden released a statement on the importance of continued vigilance in protecting US critical infrastructure, stressing the need for strong cybersecurity controls. This statement follows the Russian invasion of Ukraine, US-led sanctions, and new reporting requirements for critical infrastructure companies, which include broadband providers. The new requirements are contained in the Strengthening American Cybersecurity Act, which mandates critical infrastructure companies report certain computer security incidents to the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) within 72 hours of discovery and even faster, within 24 hours, if payment is made for ransomware.

The statement and associated fact sheet advise that critical infrastructure companies should immediately take the following steps to harden their defenses:

  1. Implement multi-factor authentication (MFA) for remote access and on all exposed systems to prevent unauthorized access (note that the standard use of username/password is not sufficient protection).
  2. Ensure data is backed up and encrypted. Additionally, backups should be tested for recovery and separated from the rest of the network to guard against ransomware.
  3. Develop an incident response plan that includes reporting guidelines and considers these four recommendations from the NIST Computer Security Incident Handling Guide:
    a. Preparation;
    b. Detection and analysis;
    c. Containment, eradication, and recovery; and
    d. Post-incident activity.
  4. Educate and test employees on security awareness on a variety of topics and ensure they take part in business continuity and incident response exercises, so they are prepared when an incident occurs.
  5. Assess systems and processes using modern tools and mitigate discovered vulnerabilities via patching or system hardening.
  6. Implement network monitoring and logging to detect attacks and prevent a major incident from occurring.

For questions concerning this or any other cybersecurity issue, please press the button below to connect with one of our subject-matter experts.

ReConnect Challenge Process Begins: Are You Prepared to Defend Your Service Area?

2022-03-18T19:24:40-04:00March 18, 2022|e-Lerts|

JSI Encourages All Providers to Determine If Their Service Areas Are Impacted by the Proposed Service Areas in Applications

This week, the USDA released three public notices listing 288 applications that have been filed under the ReConnect III program. These announcements open a 45-day window for existing service providers to challenge the validity of the funded service areas proposed by ReConnect applicants that overlap with your company’s existing service area. If a ReConnect application’s proposed service area overlaps with your service area, and you can show that you are providing broadband speeds of at least 100/20 Mbps, your challenge could be successful. This brief window is now open and will close on April 28, 29, or 30, 2022, depending on the release date of the public notice announcing the application.

USDA is issuing these announcements daily, so keep checking to see if any of the applications propose overlapping service. More information on these applications can be found here. To depict the extent of the overlap between the current service provided and the proposed funded service areas (PFSAs) under the ReConnect program, JSI has created maps for all the applications announced to date. As additional public notices are released, we will continue to review the data to help companies determine the extent of any overlap.

If an application impacts your service area, and you would like to challenge that application, the USDA requires the following:

  1. A shapefile of the area in which you already provide broadband service of 100/20 Mbps.
  2. Additional information such as your company’s contact information, the technology used to provide broadband service, the type of service provided, the highest download and upload speeds available in the PFSA, and the number of households capable of and currently receiving broadband service of at least 100/20 Mbps in the PFSA you are challenging.

For more information on the process and instructions on how to submit a challenge, click here.

If you need assistance with developing your response to defend your area and for more information about the extent of the overlap and how it impacts your area, please click the button below to connect with one of our experts.

Important New Developments in National Broadband Mapping

2022-03-04T10:49:15-05:00March 4, 2022|e-Lerts|

Broadband Service Providers Should Get Ready to Upload Data This Summer

The Infrastructure Investment and Jobs Act (IIJA) directs the Federal Communications Commission (FCC) to improve broadband mapping accuracy prior to the disbursement of most of the $42 billion Broadband Equity, Access, and Deployment (BEAD) grant program. In our February 28 e-Lert, we informed clients that the FCC had announced that fixed and mobile broadband providers must input their broadband availability data into the Broadband Data Collection (BDC) platform during the filing window that begins on June 30, 2022, and ends on September 1, 2022. The submitted data must reflect broadband availability as of June 30, 2022. The FCC has not yet finalized its detailed data specifications that will instruct providers on how to prepare and format their BDC data submission.

Importantly, the BDC data submission does not replace the FCC’s Form 477 data submission. Providers will be required to upload data into the BDC system—using the yet to be announced FCC specifications—in addition to uploading their Form 477 data.

One critical component to the FCC’s BDC mapping effort was the selection of a Broadband Serviceable Location Fabric (BSLF) contractor. The BSLF forms the mapping structure for the BDC platform and contains the broadband location data used to support the BDC program. The FCC received bids for this work and awarded the contract to CostQuest Associates (CostQuest). Another bidding entity challenged the FCC’s award, thereby suspending the contract award until the GAO reviewed the bidder’s protest. On February 24, the GAO denied the losing bidder’s protest, and the contract was officially awarded to CostQuest.

That GAO action clears the way for the BDC platform to be finalized. And providers will input their broadband availably data this summer. Notably, the FCC may open the BDC input window earlier than June 30 if the system is ready. The next action related to BDC input is for the FCC to deliver data submission instructions to providers so that provider data can be formatted for BDC input.

The FCC understands that the BDC mapping results are critical for BEAD grants, and JSI expects it will make the BDC data specifications instructions available as soon as possible, thereby giving providers sufficient time to meet the September 1 deadline.

If you have any questions about the BDC or how JSI can help you with the BDC input process, please click the button below to connect with one of our experts.

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